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					Navigating Through
        the
  Audit Process
Schools and Libraries Training
September and October 2008
   Audits:
Documentation
   Document Retention
        Requirements

• Applicants and service providers must maintain program
  documentation for a period of at least five (5) years from last date
  of service.

• All applicants and service providers are required to retain:
   – receipt and delivery records relating to the technology plans
   – pre-bidding
   – bidding
   – contracts
   – application process
   – invoices (financial and E-rate Form 472/474)
   – provision of services, and other matters relating to the
      administration of the Universal Service Fund
          Example


• For example, if a service provider
  provides Internet access to an applicant
  for Funding Year 2005 (July 1, 2005 -
  June 30, 2006), both the applicant and
  the service provider must retain all
  records on this transaction until at least
  June 30, 2011.
    Why Conduct
         Audits?

• Ensure compliance with FCC Rules.
• Recover funds for rule violations.
• Ensure equitable contributions to USF
  (recoveries lower contribution factor).
• Prevent, detect and deter waste, fraud,
  and abuse.
• Ensure public confidence in the efficiency
  of the federal universal service programs.
• Required by law

                                               5
              Types
           of Audits

USAC Internal Audit Division (IAD) Audit
• Performance Audit

FCC OIG IPIA Audits




                                           6
       IPIA Round
         1 Results

• Causes of improper payments:
  – Lack of documentation.
    • Most often occurred with respect to invoices
      supporting reimbursement forms.
    • Also included documentation supporting discount
      calculation, contracts with service providers and
      competitive bidding documents.
       – In most cases, the lack of documentation resulted from
         beneficiaries not maintaining files designed specifically
         to support their E-rate requests.


                                                                     7
    IPIA Round 1
         Results

• Causes of improper payments:
  – Inadequate asset tracking systems.
    • Beneficiaries did not maintain accurate inventory
      records, therefore auditors could not account for
      all funded equipment.




                                                          8
           IPIA Round
             1 Results
• Causes of improper payments cont.:
  – Discount calculation discrepancies.
     • For 20 % of the selected FRNs, the auditors noted
       differences in the Block 4 numbers when compared to the
       beneficiaries’ supporting documentation.
         – These differences were mainly attributed to beneficiaries not
           maintaining the actual source date used to complete Block 4.
           Instead, the beneficiaries provided the auditors with data from
           the same general time period.

  – Funded services in ineligible locations.
     • Services and equipment were funded for ineligible entities,
       such as pre-K or juvenile justice in states where they are
       not recognized as elementary or secondary schools.

                                                                             9
            The Audit
             Process
• Announcement letter
  – Phone call to answer questions and discuss site
    visit.
• Documentation requests
  – Documents received within 2 weeks of audit
    announcement.
  – Documents received at the time of site visit.
• Entrance Conference
  – Formal discussion to introduce audit staff, audit
    objectives, overview of the process, reporting and
    timing.
                                                         10
            The Audit
             Process
• Field Work
  – Site visits vary in length.
  – Field work is performed both at the beneficiary site
    and at auditor offices.
• Reporting
  – Performance Audit
     • Compliant, Generally Compliant, Not Compliant
     • Detailed Audit Findings (DAFs)
     • Other Matters
  – Attestation Audit
     • Unqualified, Qualified, Adverse, Disclaimer
     • Audit Findings
     • Management Letter



                                                           11
           The Audit
            Process
• Exit Conference
   – Discuss audit findings in detail.
• Management Responses
   – Beneficiary Response.
   – USAC Management Response.
• Presentation to the Board
   – Reports presented in open session at the
     Schools and Libraries Committee.
• Final report sent to applicant.

                                                12
 SLD Post Audit
      Follow-up
• Based on FCC Directive
• Email sent to beneficiary to follow-up on
  audit findings
  – Request for documentation.
     • Auditor/USAC recommended procedures.
     • Additional information related to the audit.
  – Tip Sheet.
  – Website Reference.

                                                      13
   SLD Post Audit
        Follow-up
• Non-compliance letters
  – Sent for audits where conclusion is not compliant or
    adverse.
  – Request for documentation.
     • Auditor/USAC recommended procedures.
     • Additional information related to the audit issues.
  – Sent to applicant, service provide or both.
  – 6 months to respond.
     • Funding is placed on hold until response is received.
     • If no response is received, funding will be denied.
  – S&L Audit response will contact beneficiary after 1
    month to confirm receipt and answer questions.
                                                               14
 Recoveries and
       Appeals

• Auditees have 60 days to appeal
  decisions made or actions taken by
  USAC (47 C.F.R. §§ 54.719, 54.720).




                                        15
      Examples of rule
        violations that
     warrant recovery?
• Insufficient documentation of the competitive
  bidding process.
• Lack of necessary resources.
• Service substitutions that would not meet criteria established
  in the rules.
• Receipt of duplicative services.
• Failure to pay non-discounted share.
• Failure to complete service(s) within the funding year.
• Discount calculation violation.
• Services not provided for full funding year.
• Failure to have an approved technology plan.



                                                                   16
It is important to know
  who violated the rule



• USAC seeks recovery from the party or parties
  in the best position to prevent the rule violation.

• USAC must determine whether the applicant,
  service provider, or both are responsible for the
  rule violation.




                                                        17
How does USAC determine
   the responsible party?



• The FCC has laid out general guidelines which USAC
  built into its procedures:
   – Service Provider recovery situations:
       • Failure to properly bill for supported services.
       • Failure to deliver services within the relevant funding year.
       • Delivering services that were not approved on FCC Form 471.
   – School or Library recovery situations:
       •   Violation of the competitive bidding requirements.
       •   Insufficient resources to make use of the supported services.
       •   Incorrect calculation of the discount percentage.
       •   Failure to pay the non-discount portion.
       •   BEAR amount exceeds amount of invoices received from service
           provider.


                                                                           18
          What is a
          COMAD?

• A COMAD, or commitment adjustment, is where USAC
  determines that funds were committed in violation of
  program rules.

• When a COMAD is discovered, USAC must then adjust
  those funding commitments.

• If the amount of the revised commitment (original
  commitment less COMAD amount), is less than the
  disbursed amount, then USAC will seek recovery of the
  difference.


                                                          19
    Examples of a
                    COMAD
• Funding approved for ineligible services.

• Funding approved at a discount rate higher than that which can be
  supported.

• Funding for services requiring a tech plan, when no tech plan is in
  place.

• Funding provided when the competitive bidding requirements have
  not been met.

• USAC was invoiced in excess of the amount the applicant was
  invoiced by the service provider


                                                                        20
          What is a
            RIDF?
• A RIDF is where USAC discovers that funds were
  disbursed in error, but the decision to commit the funds
  was correct. USAC will seek recovery, however, the
  commitment amount will not be adjusted.

• Once the RIDF has been repaid, SLD will pay any valid
  invoices for the funding request.




                                                             21
  Examples of a
          RIDF
• Funds disbursed in excess of the services delivered.

• Funds disbursed for services not approved on FCC Form
  471.

• Non-COMAD recoveries are generally discovered via the
  audit process.




                                                         22
Navigating Through
 the Audit Process
      Section II
   How to prepare
     for an audit?
• Provide documentation in a timely manner.
   – The efficiency of the audit will depend on the
     availability of your staff and the condition of the
     documentation made available prior to and/or during
     the course of the audit.
• Ask questions to ensure you are providing adequate
  documentation.
• Keep accurate and organized records.
   – E-rate binder, organized by Funding Year.
• Maintain documents for 5 years after the last date to
  receive service.
• DOCUMENT everything!
                                                           24
               Eligibility
Documentation auditors may request
  – Financial Statements
      • Applicants may not have endowments exceeding $50 million.

  – Non-profit status (primarily for private and charter schools) –
    IRS not-for-profit determination letter.
      • Schools and libraries operating as for-profit businesses are not
        eligible for funding.

  – For Head Start, Pre-K, Juvenile Justice and Adult Education
    facilities – documentation from your state showing that these
    facilities meet the definitions of elementary or secondary
    schools.



                                                                           25
          Eligibility

Common findings

• USAC is invoiced for equipment or
  services delivered to ineligible entities.
     • Possible recommendation of recovery of funding
       for equipment or services delivered to ineligible
       entities.




                                                           26
        Technology
             Plans
Documentation auditors may request
  – Copy of a draft plan dated prior to Form 470 submission.
     • In the Fifth Report and Order, the FCC emphasized that applicants
       are still expected to develop a technology plan prior to submitting
       a 470.
     • Must address the technologies requested on Forms 470.
     • Must contain the five required elements.
         – The plan must establish clear goals and a realistic strategy.
         – The plan must have a professional development strategy.
         – The plan must include an assessment of the telecommunication
           services, hardware, software, and other services.
         – The plan must provide a sufficient budget to acquire and support the
           non-discounted elements of the plan.
         – The plan must include an evaluation process that enables the school
           or library to monitor progress toward the specified goals and make
           mid-course corrections.

                                                                              27
       Technology
            Plans
Documentation auditors may request
 cont.
  – Copy of final technology plan and approval
    letter.
    • In the Fifth Report and Order, the FCC amended
      the rules to require that technology plans must be
      approved prior to the start of services.
    • Must address the technologies requested on
      Forms 470.
    • Must contain the five required elements.
  – Copy or Copies of updated technology plans.
                                                           28
        Technology
             Plans
Common audit findings
  – Technology plan did not contain the five required elements.
      • Possible recommendation of full recovery of all funds disbursed
        because application was not based on a bona fide request for
        services.
  – Technology plan approved after services have started.
      • Possible recommendation of recovery of funds for time period
        between start of services and technology plan approval.
  – Technology plan does not address technologies requested on
    Form(s) 470.
      • Possible recommendation of recovery of funds disbursed for the
        technology or technologies that were not addressed in the
        technology plan.



                                                                          29
       Technology
            Plans
Technology plan best practices
  – The five required elements are clearly laid out in the
    technology plan.
  – All technologies that are requested on Form(s) 470
    are addressed in the technology plan.
  – Technology plans are approved prior to the start of
    services.
  – Technology plan is approved by a SLD or FCC
    certified technology plan approver.
     • Can be located on USAC’s website at:
       http://www.usac.org/sl/tools/search-tools/tech-plan-
       approver-locator.aspx

                                                              30
Technology Plan
      Approver
        Locator




                  31
      Technology
           plans

Technology plan best practices cont.
  – Technology plan and all updated versions
    are dated.
  – Keep copies of all technology plan
    documents (draft technology plan, final
    technology plan and approval letter) in E-rate
    binder.



                                                 32
   Children’s Internet
       Protection Act
                (CIPA)
Documentation auditors may request
  – Internet Acceptable Use Policy or Internet Safety
    Policy.
     • The Internet safety policy must address the following
       issues:
         – Access by minors to inappropriate matter on the Internet and
           World Wide Web.
         – The safety and security of minors when using electronic mail,
           chat rooms, and other forms of direct electronic
           communications.
         – Unauthorized access including "hacking" and other unlawful
           activities by minors online.
         – Unauthorized disclosure, use, and dissemination of personal
           information regarding minors.
         – Measures designed to restrict minors' access to materials
           harmful to minors.

                                                                       33
                     CIPA

Documentation auditors may request cont.
  – Record of a public hearing or notice.
     • Per the FCC’s CIPA Order, there must be reasonable public
       notice and at least one public hearing or meeting to discuss
       the proposed Internet safety policy and technology
       protection measure.
         – Board meeting minutes, advertisements, etc.
  – Evidence a technology protection measure was in
    place during the audited Funding Year.
     • Filter reports.
     • Documentation showing the purchase or renewal of filter
       equipment, software and/or licenses.
         – Must cover the Funding Year(s) being audited.

                                                                 34
                    CIPA

Common audit findings
  – Applicant did not have an Acceptable Use Policy or
    Internet Safety Policy.
     • Possible recommendation of recovery of all funds disbursed
       for Priority 2 services.
  – Applicant’s Acceptable Use Policy or Internet Safety
    Policy does not contain the required five elements.
     • Possible recommendation of recovery of all funds disbursed
       for Priority 2 services.
  – Applicant did not conduct a public hearing or notice,
    or could not produce documentation to show that
    public hearing or notice occurred.
     • Possible recommendation of recovery of all funds disbursed
       for Priority 2 services.

                                                                35
                  CIPA

Best practices
  – The five required elements are clearly laid out in the
    Acceptable Use Policy or Internet Safety Policy.
  – Documentation supporting a public hearing or notice
    is maintained.
  – On the first day of the Funding Year, and periodically
    throughout the year, common filter reports (i.e. most
    accessed websites or most blocked websites) are
    run, printed and maintained.
  – Documentation supporting the purchase or renewal
    of filter equipment, software or licenses is
    maintained.
  – All documentation supporting compliance with CIPA
    rules is maintained in E-rate binder.
                                                         36
              Discount
            Calculation
Documentation auditors may request
   – Report of NSLP, Survey, Provision I, II, III numbers, etc. used
     to complete Block 4 of Form(s) 471.
       • Auditors will expect report data matches the data on Block
         4.
   – NSLP, Provision I, II, or III documentation submitted to the state
     or USDA.
   – If using NSLP numbers – evidence of verification per USDA
     guidelines.
   – Sample of applications or surveys collected.
       • In July 2008, the FCC OIG and USDA reached an
         agreement that will allow sharing of NSLP information.


                                                                          37
USDA Agreement




                 38
         Discount
       Calculation

Common audit findings
  – Applicant can not provide discount
    calculation data used to complete Block 4 of
    Form(s) 471. Auditors must be able to
    perform recalculation of discount using other
    available data.
    • Possible recommendation of recovery of
      disbursed funding equal to the difference between
      the discount calculated by the applicant and the
      re-calculated discount performed by the auditors.
                                                      39
          Discount
        Calculation
Common audit findings cont.
  – Applicant uses ineligible discount calculation
    method.
     • Possible recommendation of full recovery of all disbursed
       funds.
  – Applicant uses NSLP applications as survey.
     • Possible recommendation of recovery of disbursed funding
       equal to the difference between the discount calculated by
       the applicant using the survey method and the re-calculated
       discount performed by the auditors using the actual NSLP
       numbers.


                                                                   40
        Discount
      Calculation
Common audit findings cont.
  – Consortium lead does not obtain or maintain
    discount calculation documentation of its
    member schools or districts.
    • Possible recommendation of recovery of all
      disbursed funding or recovery of disbursed
      funding equal to the difference between the
      discount calculated by the applicant and the re-
      calculated discount performed by the auditors
      using the discount calculation data obtained from
      the member schools or districts.

                                                      41
         Discount
       Calculation
Best practices
  – Reports containing the data used to complete Block
    4 of the Form(s) 471 are maintained. Libraries and
    Consortium leads are expected to obtain and
    maintain the discount calculation documentation
    used to complete their application(s).
  – Document the method used to calculate discount.
  – All documentation is maintained in E-rate binder.




                                                         42
      Competitive
         Bidding
Documentation auditors may request
  – State and local procurement regulations or policies.
     • FCC Rules state applicants must follow all state and local
       procurement regulations or policies in addition to the FCC
       Rules.
  – Request For Proposal (RFP), Request For Quote
    (RFQ), Public Notice, Advertisement, Emails, etc.
  – All vendor responses and bids received (winning and
    losing).
     • In the Fifth Report and Order, the FCC specifically stated
       that all bids must be maintained.

                                                                    43
      Competitive
         Bidding
Documentation auditors may request cont.
  – Bid evaluation criteria, evaluation matrix, bid ratings.
  – Memorandums, Board minutes, notes to file
    pertaining to procurement or bid evaluation process.
  – Signed and dated contracts, service agreements,
    notice of award letters, etc.
  – Contract amendments, addendums, extensions, etc.
  – State master contracts.
  – Vendor correspondence.


                                                           44
          Competitive
             Bidding
Common audit findings
   – Documentation to support competitive bidding process was not
     maintained.
       • Possible recommendation of recovery of all funds
         disbursed.
   – Applicant did not consider all bids received.
       • Possible recommendation of recovery of all funds
         disbursed.
   – Applicant enters into agreement with a service provider prior to
     the 28-day waiting period after filing FCC Form(s) 470.
       • Possible recommendation of recovery of all funds disbursed
         for services associated with the agreement or contract prior
         to the 29th day.



                                                                        45
       Competitive
          Bidding
Best practices
  – Applicant thoroughly documents the competitive
    bidding process:
     • Maintains copies of RFPs, RFQs, etc.
     • Maintains copies of all bids received (winning and losing).
     • If no bids received in response to 470 or RFP/RFQ,
       applicant contacts service providers to solicit bids (this
       process should be documented/memorialized in a memo or
       email to the file)
     • Maintains copies of all bid evaluations.
     • Maintains copies of all correspondence with interested
       vendors.
  – Applicant develops bid evaluation matrix.
     • Price is the primary factor.
     • Only relevant factors considered.
                                                                     46
     Service Delivery
       and Inventory
        Management

Documentation auditors may request
  – Fixed asset listing/Equipment inventory.
  – Equipment packing slips.
  – Documentation supporting receipt of
    maintenance services received.
  – Documentation supporting applicant receipt
    of equipment installation (sign-off of work
    completed).

                                                  47
    Service Delivery
       and Inventory
   Management cont.
Common audit findings
  – Funded equipment is not in use.
     • Possible recommendation of recovery of funds disbursed
       for equipment that is not in use.
  – Funded equipment can not be located.
     • Possible recommendation of recovery of funds disbursed
       for equipment that can not be located.
  – Ineligible equipment or services purchased with SLP
    funding.
     • Possible recommendation of recovery of funds disbursed
       for ineligible equipment or services.
  – Spare equipment is purchased with SLP funding.
     • Possible recommendation of recovery of funds disbursed
       for spare equipment.

                                                                48
Spare Equipment




                  49
         Service Delivery
            and Inventory
     Management cont.
Common audit findings cont.
  – Equipment is installed in ineligible locations.
      • Possible recommendation of recovery of funds
        disbursed for equipment installed in ineligible
        locations.
  – Applicant does not maintain documentation to show
    that maintenance services are received.
      • Possible recommendation of recovery of funds
        disbursed for receipt of services that can not be
        verified.


                                                            50
         Service Delivery
             and Inventory
              Management
Best practices
  – Applicants maintain equipment inventory with
     enough detail to locate all equipment funded by SLP.
      • Information to include, Funding Year, 471
        number, FRN, Location, Serial number, Make &
        Model, USAC invoice number, Install Date,
        Customer Bill Information, Replacement Date,
        etc.
          – Sample inventory can be located at:
          http://www.usac.org/_res/documents/sl/pdf/2007
            _training/samples-checklist-inventory-list.pdf

                                                             51
Sample Equipment
        Inventory




                    52
 Service Delivery and
           Inventory
        Management

Best practices cont.
  – Applicants verify work performed and
    maintain documentation stating such.
    • When equipment or wiring is installed, applicant
      performs walk through and documents
      acceptance of work performed.
    • When maintenance is performed, applicant
      maintains documentation showing date of
      maintenance and detail of work performed.
  – All documentation is maintained in E-rate
    binder.
                                                         53
    Effective Use

Documentation auditors may request
  – Inventory of end user computers located in
    Block 4 entities.
  – Maintenance contract(s) for end user
    computers.
  – Professional development training
    log/curriculum.
  – Sign-in/attendance sheets from training
    sessions.
  – High level network diagram
                                                 54
    Effective Use

Common audit findings
  – Applicant does not possess, or has not
    budgeted for the purchase of, a sufficient
    number of end user computers.
    • Possible recommendation of recovery of funds
      disbursed for Internet Access, Internal
      Connections and/or Basic Maintenance of Internal
      Connections.
       – In the Fifth Report and Order the FCC clarified that full
         recovery of funds disbursed for all relevant funding
         requests was warranted in cases where beneficiaries
         do not have sufficient computer equipment.

                                                                     55
    Effective Use

Common audit findings cont.
  – Applicant did not adequately train staff on the
    use of funded technologies.
     • Possible recommendation of recovery of funds
       disbursed.
        – In the Fifth Report and Order the FCC clarified that full
          recovery of funds disbursed for all relevant funding
          requests was warranted in cases where beneficiaries
          do not sufficiently train staff on the use of the supported
          technologies.


                                                                    56
    Effective Use

Common audit findings cont.
  – Applicant did not have the necessary internal
    connections to effectively use the supported
    services.
    • Possible recommendation of recovery of funds
      disbursed for the portion of the funded Internet
      Access that the auditors determined was not used
      effectively.
       – In the Fifth Report and Order the FCC clarified that full
         recovery of funds disbursed for all relevant funding
         requests was warranted in cases where beneficiaries
         do not have sufficient internal connections.

                                                                     57
    Effective Use

Common audit findings cont.
  – Applicant does not have adequate electrical
    capacity to make use of the supported
    services.
    • Possible recommendation of recovery of funds
      disbursed for the portion of funding the auditors
      determined was subject to the inadequate
      electrical capacity.
       – In the Fifth Report and Order the FCC clarified that full
         recovery of funds disbursed for all relevant funding
         requests was warranted in cases where beneficiaries
         do not have sufficient electrical capacity.

                                                                     58
             Effective
                  Use
Best practices
  – Applicant documents inventory of end user
    computers in use.
     • This number does not have to be exact, however, it should
       at least be a good faith estimate. Please note that while
       performing inventories, auditors may make note of the
       number of computers in classrooms and administrative
       offices.
  – Applicant maintains a list of the operating systems
    and software in use on end user computers.
  – Applicant maintains copies of staff training syllabus
    and sign-in sheets.
  – Applicant maintains copies of network diagrams.
  – All documentation is maintained in E-rate binder.

                                                                   59
  Invoicing, Payments
 and Reimbursements


Documentation auditors may request
  – Customer bills – all pages, not just
    summaries.
  – Reconciliation worksheets.
  – Proof of payment of non-discounted
    amounts.
    • Cancelled checks, front and back
    • Bank statements
  – Proof of reimbursement from vendor.

                                           60
    Invoicing, Payments
   and Reimbursements

Common audit findings
   – Ineligible items or services invoiced to USAC.
       • Possible recommended recovery of funds disbursed for
          ineligible items or services.
   – Billing to the cap – applicant seeks reimbursement for full
     committed amount, even though they were billed less.
       • Possible recommended recovery of funds disbursed for
          unsupported amounts.
   – USAC is invoiced for equipment or services that were not
     provided or not installed.
       • Possible recommended recovery of funds disbursed for
          equipment or services that were not provided or not
          installed.



                                                                   61
  Invoicing, Payments
 and Reimbursements


Common audit findings cont.
  – Applicant has not paid its non-discounted
    share of disbursed funds.
    • Possible recommendation of recovery of funds
      disbursed relative to the applicants non-
      discounted share.
       – Per the Fifth Report & Order, the FCC concluded that
         90 days after delivery of service is a reasonable
         timeframe within which bills should be paid.



                                                                62
  Invoicing, Payments
 and Reimbursements


Common audit findings cont.
  – Applicant or service provider does not
    maintain adequate records to support the
    amount invoiced to USAC for equipment or
    services.
    • Possible recommendation of recovery of funds
      disbursed for which adequate documentation
      could not be located.



                                                     63
  Invoicing, Payments
 and Reimbursements


Best practices
  – Detailed bills – the bills should provide
    details pertaining to the equipment or
    services delivered.




                                                64
Bad Bill
Example
            Bad Bill
           Example




                       65
Good Bill
Example
            Good Bill
            Example




                        66
  Invoicing, Payments
 and Reimbursements


Best practices cont.
  – All bills are maintained, not just summary
    pages.
  – Copies of cancelled checks, or other proof of
    payment of non-discounted portion, is
    obtained and maintained.
  – All bills are paid in a timely manner - ≤ 90
    days.


                                                67
  Invoicing, Payments
 and Reimbursements


Best practices cont.
  – Applicant performs a reconciliation or
    verification of all bills received.
    • Shows any ineligible items or services deducted
      from amount invoiced to USAC.
    • Shows applicant’s verification that equipment or
      services were delivered or installed.




                                                         68
                 Reconciliation Example
Reconciliation




                                          69
  Invoicing, Payments
 and Reimbursements


Best practices cont.
  – Applicant maintains copies of reimbursement
    check(s) from service provider(s).
  – All documentation is maintained in E-rate
    binder.




                                              70
        Miscellaneous


Other documentation auditors may request
• Copies of all forms and correspondence with
  USAC.
  –   470
  –   471
  –   Item 21 Attachments
  –   472
  –   474
  –   486
  –   500
                                                71
       Miscellaneous


Other documentation auditors may request
  cont.
  –   SPIN change documents
  –   Appeal documentation
  –   Service Substitution documentation
  –   Quarterly Disbursement Reports
  –   RNL(s), RAL(s), FCDL(s), 486 notification letter, 500
      notification letter, BEAR notification letter, etc.
       • While the documentation sent to PIA is provided to the
         auditors, auditors prefer to view the original documentation.

                                                                     72
            Helpful
       Information
• Code of Federal Regulations (C.F.R.)
  – http://www.access.gpo.gov/nara/cfr/cfr-table-
    search.html#page1
    • Title 47
       – Part 54
          » 54.500 – 54.523




                                                    73
             Helpful
        Information
• Audit information on SLD’s website
   – http://www.usac.org/sl/about/audits/default.aspx




                                                        74
           Helpful
      Information

• FCC Orders on USAC’s website
  – http://www.usac.org/_res/documents/about/p
    df/fcc-orders/all-fcc-usf-orders.pdf




                                             75
           Helpful
      Information

• Audit inquiry mailbox
  – auditinquiry@usac.org




                            76
            Appeals

• Decisions of the SLD can be appealed to
  the SLD or to the FCC
• Can be filed electronically or on paper
• Must be received or postmarked within 60
  days of the SLD decision
• See Appeals Procedure in the Reference
  area for specific guidance
• Requests for waivers of rules must be filed
  with the FCC
                                            77
     Contact for
     Assistance
       Julia Benincosa
  WV State E-rate Coordinator

       Phone: 304-558-7880
         Fax: 304-558-2584
Email: jbeninco@access.k12.wv.us

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Description: Request to Bank for Front and Back Cancelled Check document sample